phdwin Privacy Policy — Your Data, Protected

1 Introduction

phdwin ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users who access or register on our online casino and sports betting platform at phdwin.net. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

This Privacy Policy applies to all personal data collected by phdwin through the phdwin.net website, mobile-optimised interfaces, customer support channels, and any other touchpoint through which you interact with phdwin. It covers Filipino players in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines.

Please read this Privacy Policy carefully before registering a phdwin account or submitting any personal information to us. If you have questions about how phdwin handles your data, you may contact our Data Protection Officer at any time using the details provided in Section 15 of this policy.

2 Definitions

For the purposes of this Privacy Policy, the following definitions apply:

• "Personal Data" means any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained, or when put together with other information would directly and certainly identify an individual.
• "Sensitive Personal Information" means personal data about an individual's race, ethnic origin, marital status, age, colour, religious, philosophical or political affiliations, health, education, genetic or sexual life, proceedings for any offence, government-issued identification numbers, financial information, and any information specifically established by an executive order or act of Congress.
• "Processing" means any operation or set of operations performed upon personal data, including but not limited to collection, recording, organisation, storage, updating, modification, retrieval, use, consolidation, blocking, erasure, or destruction.
• "Data Subject" means a registered or prospective phdwin player whose personal data is collected and processed by phdwin.
• "Data Controller" means phdwin, the entity that determines the purpose and means of processing personal data.
• "Data Processor" means any third party that processes personal data on behalf of and under the instruction of phdwin.
• "NPC" means the National Privacy Commission of the Philippines, the regulatory body responsible for administering and implementing the Data Privacy Act.
• "Consent" means any freely given, specific, informed indication of will, whereby the Data Subject agrees to the collection and processing of their personal data for identified purposes.

3 Personal Data We Collect

3.1 Registration Data

When you create a phdwin account, we collect the following personal data as part of the registration process:

• Full legal name (first name and last name);
• Date of birth (to verify the 21+ age requirement under Philippine gaming regulations);
• Residential address, including city and province;
• Valid email address;
• Mobile phone number;
• Username and password (password is stored in hashed form only).

3.2 KYC Verification Data

To comply with PAGCOR requirements and Philippine anti-money laundering laws, phdwin collects the following identity verification documents prior to processing your first withdrawal:

• A copy of a valid government-issued photo ID (e.g., PhilSys National ID, passport, UMID, driver's licence, voter's ID, or SSS/GSIS ID);
• A proof of address document dated within the last three months (e.g., a utility bill, bank statement, or barangay clearance);
• Where required by AML regulations, a selfie or liveness check image for biometric identity confirmation.

3.3 Financial Data

When you make deposits or withdrawals via phdwin, we collect payment-related information including your GCash number, Maya (PayMaya) account number, bank account details (BPI, BDO, Metrobank), or reference numbers associated with cash payment channels such as 7-Eleven CLiQQ. phdwin does not store full credit card or debit card numbers on its servers.

3.4 Gameplay and Transaction Data

phdwin automatically records all account transactions and gameplay activity, including: deposit and withdrawal history; game session records including game type, stake, outcome, and session duration; bonus credits and wagering activity; and communications with phdwin's customer support team.

3.5 Technical and Device Data

When you access phdwin, our servers automatically collect certain technical data about your device and connection, including: IP address; browser type and version; device type and operating system; referring URL; and session timestamps. This data is used for security monitoring, fraud prevention, and service optimisation.

4 How We Collect Your Data

phdwin collects personal data through the following channels:

• Directly from you — through account registration forms, KYC submission portals, payment processing pages, customer support interactions, and feedback or survey responses;
• Automatically — through cookies, web server logs, and similar tracking technologies when you browse or interact with the phdwin platform (see Section 7 for details);
• From third parties — from identity verification service providers that assist with KYC checks, from payment processors when confirming transaction status, and from fraud detection partners that help phdwin identify suspicious activity patterns;
• From publicly available sources — where permitted by law, phdwin may supplement account records with information from government registries, sanctions lists, or other publicly accessible databases to meet AML compliance obligations.

5 Purpose & Legal Basis for Processing

5.1 Service Delivery

The primary purpose for which phdwin collects and processes personal data is to provide, operate, and improve the phdwin online casino and sports betting platform. This includes account creation and management, processing deposits and withdrawals, facilitating gameplay, administering bonuses and promotions, and providing customer support.

5.2 Legal and Regulatory Compliance

phdwin is required by Philippine law to collect and retain certain personal data for the purposes of: age verification (21+ requirement); identity verification (KYC under PAGCOR regulations); anti-money laundering compliance under the Anti-Money Laundering Act (AMLA) as amended; and reporting obligations to PAGCOR and other regulatory bodies.

5.3 Security and Fraud Prevention

phdwin processes personal data for the purpose of securing accounts, detecting and preventing fraud, identifying prohibited conduct such as multi-accounting and bonus abuse, and protecting the integrity of the platform for the benefit of all players.

5.4 Marketing Communications

Where you have provided separate, specific consent to receive marketing communications, phdwin may use your email address and mobile number to send you promotional offers, game announcements, and personalised recommendations. You may withdraw consent to marketing communications at any time by using the unsubscribe link included in every marketing email or by contacting phdwin support.

5.5 Legal Basis

phdwin processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent — for registration, marketing communications, and optional data uses;
• Contractual necessity — for processing data required to deliver the services you have requested under the phdwin Terms & Conditions;
• Legal obligation — for KYC, AML, and regulatory reporting requirements;
• Legitimate interests — for fraud prevention, security monitoring, and platform analytics, where these do not override your fundamental rights.

6 Data Sharing & Disclosure

6.1 Third-Party Service Providers

phdwin shares personal data with carefully selected third-party service providers that assist in operating the platform. These include: payment processors and e-wallet service providers (GCash, Maya, BPI, BDO, Metrobank, GrabPay, and 7-Eleven CLiQQ); identity verification and KYC providers; fraud detection and security analytics partners; cloud infrastructure and hosting providers; and customer support platform providers. All third-party processors are bound by data processing agreements that require them to handle your data only for the purposes instructed by phdwin and in compliance with applicable Philippine privacy laws.

6.2 Regulatory and Law Enforcement Authorities

phdwin is required by law to disclose personal data to regulatory and law enforcement authorities in certain circumstances, including: reports to PAGCOR in connection with gaming regulatory compliance; suspicious transaction reports to the Anti-Money Laundering Council (AMLC); responses to valid court orders, subpoenas, or legal process; and disclosures required to protect the safety of the public or prevent serious harm.

6.3 No Sale of Personal Data

phdwin does not sell, rent, lease, or otherwise transfer your personal data to third parties for their own commercial or marketing purposes. Any data sharing arrangement with third parties is strictly limited to service delivery, regulatory compliance, or security purposes as described in this Privacy Policy.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. phdwin uses cookies and similar tracking technologies to enable core platform functionality, remember your preferences, and gather analytics data that helps us improve the player experience.

7.2 Types of Cookies Used

• Strictly Necessary Cookies: These are required for the phdwin platform to function. They enable session management, authentication, and security features. You cannot opt out of strictly necessary cookies without losing access to core platform features.
• Functional Cookies: These remember your preferences such as language settings, display options, and account customisations. They improve your experience but are not essential to platform operation.
• Analytics Cookies: These help phdwin understand how players use the platform, which games are most popular, and where technical issues occur. Analytics data is aggregated and does not personally identify individual players.
• Security Cookies: These support phdwin's fraud detection and account security systems by detecting unusual login patterns and suspicious activity.

7.3 Cookie Consent and Control

On your first visit to phdwin.net, you will be presented with a cookie consent notice. You may accept all cookies, accept only strictly necessary cookies, or customise your preferences. You can also manage or delete cookies at any time through your browser settings. Note that disabling certain cookies may affect the functionality of some phdwin features.

8 Data Retention

phdwin retains personal data only for as long as is necessary for the purposes described in this Privacy Policy, or as required by applicable Philippine laws and regulations. The following general retention guidelines apply:

• Account data (registration details, gameplay history, transaction records): retained for the lifetime of the account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• KYC documents: retained for a minimum of five (5) years from the date of verification, as required under AML regulations;
• Customer support correspondence: retained for three (3) years from the date of the last interaction;
• Marketing consent records: retained for the duration of the marketing relationship and for one (1) year following withdrawal of consent;
• Technical and device data (logs): retained for twelve (12) months and then deleted or anonymised.

Upon expiry of the applicable retention period, phdwin will securely delete or anonymise your personal data in a manner that prevents re-identification.

9 Data Security

phdwin implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• AES-256 encryption for data stored at rest;
• TLS 1.3 encryption for all data in transit between your device and phdwin servers;
• Multi-factor authentication options for player accounts;
• Role-based access controls restricting internal access to personal data to employees who require it for their legitimate job functions;
• Regular penetration testing and security audits conducted by independent security specialists;
• Incident response procedures designed to detect, contain, and report data breaches in accordance with NPC requirements.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phdwin:

phdwin will respond to data subject requests within fifteen (15) working days of receipt of a complete and valid request. In complex cases, this period may be extended by a further fifteen (15) working days, and you will be notified accordingly.

11 Minors & Age Policy

phdwin's services are strictly available to persons who are 21 years of age or older, consistent with Philippine gaming regulations. phdwin does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the KYC process before any withdrawal is processed. Where phdwin identifies or is notified that a registered user is under the age of 21, the account will be immediately closed, and the matter may be reported to PAGCOR and relevant authorities as required. Any deposits received from an underage user will be handled in accordance with applicable regulatory requirements.

12 Cross-Border Data Transfers

phdwin's primary data processing infrastructure is located within or closely associated with the Philippines. In certain circumstances, your personal data may be processed by third-party service providers whose servers are located outside the Philippines — for example, cloud infrastructure providers or internationally operated fraud detection platforms.

Where such cross-border transfers occur, phdwin ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012, including the use of contractual clauses that require the overseas recipient to provide a standard of protection comparable to that required under Philippine law. phdwin will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without your prior consent or without appropriate contractual safeguards.

13 Third-Party Services & Links

The phdwin platform may reference or link to third-party services such as payment gateways (GCash, Maya, BPI, BDO) for the purpose of completing transactions. These third-party services operate under their own terms of service and privacy policies, which phdwin does not control. phdwin is not responsible for the privacy practices of third-party service providers once you leave the phdwin platform or interact directly with a third-party system.

phdwin's game content may be supplied by licensed third-party game providers. These providers may collect limited technical data (such as game session identifiers) for the purpose of operating their games and ensuring fair play. This data sharing is governed by data processing agreements and is limited to what is necessary for game operation.

14 Changes to This Privacy Policy

phdwin reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, new service features, regulatory requirements, or NPC guidance. Where changes are material, phdwin will notify registered players via email to their registered address and by displaying a prominent notice on the phdwin platform prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy reflects the date of the most recent revision. Your continued use of phdwin's services following the effective date of any update constitutes your acknowledgement and acceptance of the revised Privacy Policy. If you do not agree with the revised policy, you should cease using phdwin and close your account before the changes take effect.

Previous versions of this Privacy Policy are available upon request from phdwin's Data Protection Officer.

15 Contact Us & Data Protection Officer

phdwin has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. If you wish to exercise any of your data privacy rights, have a question about how your personal data is handled, or wish to lodge a complaint about phdwin's data processing practices, please contact the phdwin DPO using the details below:

If you are not satisfied with phdwin's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act and can investigate complaints against personal information controllers operating in the Philippines.

This Privacy Policy was last updated in January 2026. It is effective as of the date of publication. phdwin Philippines. All rights reserved.